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American Financial Services Association

NYC Department of Consumer and Worker Protection Comment Letter

NYC Department of Consumer and Worker Protection Comment Letter

This past week, AFSA’s state government affairs team sent a comment letter to the New York City Department of Consumer and Worker Protection (DCWP) on the updated proposed amendments to its rules relating to debt collectors. In the letter AFSA highlights concerns and suggests clarifications for various sections, including the scope of terms “debt collector” and “debt,” addressing the communication frequency limitations, and adding the definition of “itemization reference date.”

The letter recommends that the DCWP either mandates sending the Validation Notice post-initiation of debt collection procedures or retains the current rule language exempting those complying with TILA and the FCBA disclosures, as both revisions would benefit consumers without withholding pertinent account information.

AFSA also cites concerns of overlapping and conflicting itemization requirements with federal Regulation F, suggesting the elimination of the requirement or establishment of a safe harbor for the use of Regulation F’s model validation notice.

This letter, along with SGA’s other recent letters, can be found on the direct advocacy section of AFSA’s website.

November 30th, 2023 by

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